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Legal & Compliance

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1. Who we are

Clark Clinical Scribe is an AI-powered medical documentation service provided by Contempo Studios Ltd ("we", "us"). Registered in England and Wales. Contact: support@clarkai.app.

2. Acceptance of terms

By accessing or using Clark Clinical Scribe, you agree to these Terms. If you use Clark on behalf of a healthcare organisation, you confirm you have authority to bind that organisation.

3. Service description

Clark provides AI-assisted transcription and structuring of medical consultations into clinical documentation. The service converts audio recordings into structured clinical notes and generates referral letters. It is a documentation assistant tool, not a diagnostic or prescriptive medical device.

4. Professional responsibility

You remain fully responsible for:

  • Verifying accuracy of all generated documentation
  • Clinical decisions and patient care
  • Compliance with NHS policies, local guidelines, and professional standards
  • Ensuring appropriate patient consent for recording consultations
  • Reviewing and editing all AI-generated content before finalisation

5. Account usage and security

  • Provide accurate registration details and maintain credential confidentiality
  • One account per healthcare professional
  • No sharing of login credentials
  • Report any unauthorised access immediately

6. Service availability

We aim for 99.9% uptime but may experience maintenance periods. We will provide advance notice where practical. The service may be modified or features updated to improve functionality.

7. Intellectual property

We own the Clark platform, branding, and user interface. Medical content you create remains yours. Third-party content (Clare guidelines integration) remains property of respective owners.

8. Payment terms

Subscription fees are billed monthly or annually. NHS organisations may have special pricing agreements. VAT applies where applicable. Cancellations take effect at the end of the current billing period.

9. Warranties and disclaimers

Clark is provided "as is" and "as available." While we strive for accuracy, AI-generated content may contain errors and must be reviewed. We disclaim implied warranties to the extent permitted by law.

10. Limitation of liability

We are not liable for clinical decisions based on Clark output. Our aggregate liability is limited to fees paid in the 12 months before any claim, unless prohibited by law.

11. Indemnification

You indemnify us against losses arising from your breach of these Terms or misuse of the service.

12. Termination

Either party may terminate with 30 days' notice. We may suspend immediately for breach or security concerns.

13. Governing law

These Terms are governed by the laws of England and Wales. Courts of England and Wales have exclusive jurisdiction.

14. Changes to Terms

We will notify registered users of material changes via email with 30 days' notice.

Important: Clark Clinical Scribe is a documentation assistance tool only. It does not provide medical advice, diagnosis, or treatment recommendations.

  • Clark is an AI-powered transcription and documentation tool, not a medical device
  • All generated documentation must be reviewed and verified by qualified healthcare professionals
  • Clinical decisions remain the sole responsibility of the healthcare provider
  • AI-generated content may contain errors or misinterpretations
  • Audio quality and accent variations may affect transcription accuracy
  • Medical terminology may be incorrectly transcribed and requires professional review
  • Clare guidelines integration provides reference information only - verify current local protocols
  • Generated referral letters are drafts requiring professional review and approval
  • In emergencies, follow standard emergency protocols - do not rely on documentation tools

Clinical governance

Healthcare organisations using Clark must:

  • Ensure appropriate clinical governance oversight
  • Maintain professional indemnity insurance
  • Train staff on appropriate use of AI documentation tools
  • Implement local policies for AI-assisted documentation
  • Ensure compliance with GMC/NMC guidelines on record keeping

1. Data controller and processor

Contempo Studios Ltd is the data controller for the account data of people who use Clark (see "What we collect"). For patient data in consultations, the healthcare organisation using Clark is the data controller, and Contempo Studios Ltd processes that data on its behalf as a data processor. For data protection questions, contact: support@clarkai.app.

2. What we collect

  • Account data: Name, username, email address and, if you give it, your place of work
  • Service data: Audio recordings, transcripts, clinical notes, referral letters, timestamps
  • Technical data: IP address and browser type, recorded in server logs
  • Support data: Communications with our support team

Patient data handling: Recordings of uploaded and live consultations and of referral dictations are stored encrypted in UK Azure Blob Storage with the consultation record, and deleted automatically after 90 days, or earlier when the consultation is erased. Transcripts, clinical notes and referral letters contain patient-identifiable information and are not anonymised. They are stored encrypted in UK Azure Blob Storage until they are erased (see Data retention below). Healthcare providers are responsible for anonymisation where required.

3. Legal basis for processing

Patient data. The healthcare organisation, as controller, decides the lawful basis for recording and documenting consultations. For NHS care this is usually performance of a public task (UK GDPR Article 6(1)(e)) and, for health data, the provision of health care (Article 9(2)(h)). As processor, we use patient data only on the healthcare organisation's instructions, to provide Clark to it, and not for our own purposes.

Account, technical and support data (we are the controller):

  • Service provision and account management — contractual necessity
  • Running, securing and improving the service — legitimate interests
  • Legal and regulatory compliance — legal obligation
  • Marketing (if applicable) — consent (opt-in basis)

4. Data sharing

We share data only with:

  • Microsoft Azure for cloud infrastructure and speech-to-text, in the UK
  • Microsoft Azure OpenAI Service, used to draft clinical notes and referral letters, and to work out who is speaking, from consultation transcripts. This processing takes place in Microsoft's UK data centres. Transcripts are not anonymised
  • Clare, our own clinical guidelines service (also run by Contempo Studios Ltd), for clinical reference information
  • IONOS for account emails (sign-up, verification, password reset), sent through its email service
  • Professional regulators if legally required

5. International transfers

Consultation audio, transcripts, notes and referral letters are stored and processed in the UK (Microsoft Azure).

The clinical guidelines lookup sends only a short clinical query (the working diagnosis or a brief summary of the presenting complaint, with obvious personal identifiers removed) to an AI model that may run in Microsoft data centres outside the UK, under Microsoft's data protection terms, which include the UK International Data Transfer Addendum to the EU Standard Contractual Clauses.

Account emails are sent through IONOS. They contain your name and email address, not patient data.

6. Data retention

  • Audio recordings: Stored encrypted in UK Azure Blob Storage with the consultation record and deleted automatically after 90 days, or earlier when the consultation is erased. During a live session, audio is briefly buffered on the server until the session ends
  • Transcripts, clinical notes and referral letters: Stored encrypted in UK Azure Blob Storage until they are erased. They are not deleted automatically, and we have not yet set a fixed retention period. Clark does not yet have an erase option in the app: to have a consultation or referral letter erased, contact us
  • Account data: Retained during account lifetime plus 12 months
  • Audit logs: 24 months for compliance purposes
  • Support tickets: 24 months after closure

7. Your rights

Under UK GDPR, you have rights to:

  • Access your personal data
  • Rectify inaccurate data
  • Request erasure (subject to legal obligations)
  • Restrict processing
  • Data portability
  • Object to processing
  • Withdraw consent (where applicable)

Patients: to exercise your rights over a consultation recorded with Clark, contact the healthcare organisation (for example your GP practice) that recorded it. It is the controller of that data, and we will help it respond.

Clark users: for your account data, contact: support@clarkai.app

8. Complaints

You may lodge complaints with the Information Commissioner's Office (ICO). We encourage you to contact us first to resolve concerns, or, for patient data, the healthcare organisation that recorded your consultation.

9. Security measures

  • Encryption in transit (TLS 1.2 or higher) for all connections, including audio
  • Encryption at rest for stored data
  • Security review of the application code, and automated vulnerability scanning of every code change and of our software dependencies
  • Hosted on Microsoft Azure, whose infrastructure is ISO/IEC 27001 certified
  • Automatic deletion of audio recordings after 90 days

10. Children's data

Clark is used by healthcare professionals, not by patients. Consultations recorded with Clark may be about children. Their recordings, transcripts and notes are not anonymised, and are handled in the same way as all other patient data described on this page.

Audio processing pipeline

  1. Audio uploaded or streamed live via secure HTTPS / WebSocket connection
  2. Live audio briefly buffered on the server until the session ends
  3. Azure Speech Services transcription, in the UK
  4. Clinical note drafted from the transcript by Azure OpenAI Service, in the UK
  5. Recording stored encrypted in UK Azure Blob Storage with the consultation record
  6. Transcript and clinical note stored encrypted in UK Azure Blob Storage
  7. Recordings deleted automatically after 90 days, or earlier when the consultation is erased

Security controls

  • TLS 1.2+ for all data transmission
  • AES-256 encryption at rest
  • Passwords and keys for our services kept in encrypted Azure configuration, never in the code
  • Role-based access control (RBAC)
  • Logging of access to consultation records, and audit records of edits and erasures
  • Automated vulnerability scanning of code and dependencies

NHS assurance

Clark is working towards NHS Data Security and Protection Toolkit (DSPT) and Digital Technology Assessment Criteria (DTAC) assurance. It has not completed either yet, and it does not yet have a named Clinical Safety Officer or a DCB0129 clinical safety case. Clark does not support NHS Smartcard sign-in.

© 2025 Contempo Studios Ltd. All rights reserved.

  • Clark name, logo, and mustard colour scheme are our trademarks
  • User interface and software code are proprietary
  • Clinical content you create remains your intellectual property
  • Clare Guidelines content © National Institute for Health and Care Excellence
  • OpenAI and Azure are trademarks of their respective owners

User content licence

By using Clark, you grant us a limited licence to process your content solely for service provision. We do not claim ownership of your clinical documentation.

Copyright infringement

To report copyright infringement, contact support@clarkai.app with:

  • Description of the copyrighted work
  • Location of allegedly infringing material
  • Your contact information
  • Statement of good faith belief
  • Declaration of accuracy under penalty of perjury

Permitted use

  • Clinical documentation for legitimate healthcare purposes
  • Generation of referral letters and clinical correspondence
  • Professional medical record keeping
  • Quality improvement and audit (with appropriate governance)

Prohibited use

  • Recording without appropriate patient consent
  • Non-medical or personal use
  • Attempting to extract or reverse-engineer AI models
  • Uploading malicious files or code
  • Circumventing security measures
  • Sharing login credentials
  • Bulk processing for commercial purposes
  • Creating false or misleading medical records
  • Any unlawful or unethical use

Enforcement

Violations may result in:

  • Warning or temporary suspension
  • Account termination
  • Reporting to professional regulators
  • Legal action where appropriate

We use the following sub-processors for service delivery:

Core infrastructure

  • Microsoft Azure: Cloud hosting, blob storage, speech services

AI processing

  • Microsoft Azure OpenAI Service: GPT-4.1-mini for structuring notes and referral letters (UK South)
  • Azure Speech Services: Speech-to-text processing (UK South)

Clinical references

  • Clare (our own service, run by Contempo Studios Ltd): NICE guidelines and CKS lookups

Communication

  • IONOS: SMTP email for account emails

Microsoft's Data Protection Addendum covers the Azure services. Clare is our own service, not a third party. A data processing agreement with IONOS is not yet in place. Material changes to sub-processors will be notified to registered users.

Clark Clinical Scribe is committed to digital accessibility for healthcare professionals with disabilities.

Conformance status

We aim to meet WCAG 2.1 Level AA standards. Current conformance is partial, with ongoing improvements.

Accessible features

  • Keyboard navigation throughout the interface
  • High contrast Clark mustard colour scheme
  • Responsive design for various screen sizes
  • Clear, consistent navigation
  • Descriptive button and link text
  • Alt text for images and icons

Known limitations

  • Audio waveform visualisation may not be fully accessible to screen readers
  • Some third-party content may not meet accessibility standards

Feedback

To report accessibility issues or request assistance: support@clarkai.app

General support

Email: support@clarkai.app
Response time: Within 24 hours (working days)

Data protection

Email: support@clarkai.app

Legal matters

Email: support@clarkai.app

Clinical safety

To report a clinical safety concern: support@clarkai.app

Security incidents

To report a security incident: support@clarkai.app

Changes to this Page

We will update this page when policies change and adjust the "Last updated" date at the top. Registered users will be notified of material changes.